The UK’s Modern Slavery Act came into force in 2015, but commentators have noted that not all companies are properly fulfilling the requirements of disclosure. Companies turning over more than £36 million pounds globally and that do business within the UK must put a statement on their website noting what, if anything, they are doing to combat modern slavery. It sounds easy enough, but like so many things in compliance, the devil is in the details.
What if you don’t need to comply with the Modern Slavery Act? Well, there’s always the California Transparency in Supply Chain Act as well as U.S. Federal Regulations for government contracts over a certain value. Still not required to make modern slavery disclosures or implement modern slavery controls? Consider this- reputational risk is far and away the biggest issue with respect to modern slavery. No one wants their company to be the target of social activism over the mistreatment, abuse or death of others in the name of commerce.
My good friend Keith Read, former Head of Group Compliance at British Telecom and current Managing Director, Europe for Convercent, came up with an easy-to-use tool to help companies to gauge their compliance with the nuances of the Modern Slavery Act, and to plan their activities for the coming years.
Check out the downloadable HERE, and let me know if you have further questions about Modern Slavery and how to defend against it. You can also check out Spark Compliance Consulting’s Infographic on the Eight Weapons Compliance can employ against modern slavery (HERE).
Two years on we’re making progress (see this article by the UK’s first Independent Anti-Slavery Commissioner), but there’s still so much to do. Together, we in the compliance community can make a big difference to this seemingly intractable problem.